Anthony Botello, Forest Supervisor

Chris Prew, Recreation Program Manager

Flathead National Forest Supervisor’s Office

650 Wolfpack Way

Kalispell, MT 59901

March 13, 2026

RE: Comments on the Draft Comprehensive River Management Plan and Environmental Assessment for the Three Forks of the Flathead Wild and Scenic River System

The Flathead Lakers appreciates the opportunity to comment on the Draft Flathead Wild and Scenic River Joint Comprehensive River Management Plan (CRMP) and Environmental Assessment (EA). 

For more than six decades, our organization has worked to protect water quality and ecological health throughout the Flathead watershed, including the rivers that form the headwaters of Flathead Lake. The Flathead Lakers is a nonprofit organization with more than 1,200 members dedicated to protecting clean water, healthy ecosystems, and quality of life throughout the Flathead watershed through research, advocacy, and collaboration. 

The North, Middle, and South Forks of the Flathead River represent one of the most intact river systems in the lower 48 states and provide exceptional ecological, recreational, and economic value to the region. Protecting the Outstandingly Remarkable Values (ORVs) of these rivers - including water quality, fisheries, wildlife habitat, and scenic character - is essential for the long-term health of both the Wild and Scenic River corridor and the broader Flathead watershed. 

Flathead Lakers appreciates the substantial effort undertaken by the U.S. Forest Service and Glacier National Park to update the Comprehensive River Management Plan. The proposed CRMP contains several important strengths and management tools that could significantly improve protection of river resources. However, several aspects of the plan require additional clarification and strengthening to ensure the long-term protection of water quality, fisheries, and ecological integrity.

Strengths of the Proposed CRMP

  • The EA appropriately identifies specific locations where recreation-related impacts, including human waste and bank erosion, are already occurring, including Blankenship Bridge (dispersed camping), Great Northern Flats, and the Canadian Border access site. Identifying these sites provides an important starting point for corrective actions.

  • We support proposed management measures that address immediate contamination risks to water quality associated with recreation pressures, including prohibiting motor-vehicle camping or parking on gravel bars and requiring solid human-waste containment within 200 feet of the river’s edge. 

  • The CRMP proposes establishing a monitoring framework to track E. coli, BMP implementation and effectiveness, and aquatic habitat conditions. The establishment of indicators, triggers, and thresholds provides an important foundation for adaptive river management.

  • We appreciate that the CRMP includes a proposal to strengthen coordination among Glacier National Park, the U.S. Forest Service, and BNSF Railway to address potential spill risks along the Middle Fork corridor. Given the proximity of rail transportation and the importance of the Middle Fork for both ecological and water-quality values, proactive spill prevention and response coordination will be an important component of river protection. We recommend that the CRMP include a clear pathway and timeline for developing a spill-prevention and response plan outlining prevention measures, spill-response protocols, containment planning, and identification of priority response locations where limited access could delay containment along the river corridor.

  • The proposed user monitoring system has the potential to generate valuable information about visitor numbers, seasonality, and patterns of river use, all of which are needed to evaluate user impacts and thresholds.

Areas Where the CRMP Should Be Strengthened

Scenic easements and private land stewardship

The original 1980 Flathead Wild and Scenic River Management Plan recognized that private lands within the river corridor could significantly influence scenic character and resource conditions. That plan emphasized the importance of scenic easements and continued monitoring to protect corridor values. Because private lands remain an important component of the river corridor, the CRMP should clearly describe:

  • the current status and extent of scenic easements within the corridor, 

  • how easement compliance will be monitored and enforced.


Water quality protection

Maintaining the exceptional water quality of the Flathead River system must remain a central management priority. The EA identifies localized impacts associated with dispersed recreation sites and access areas, and states that water quality was not identified as a limiting attribute in the visitor capacity analysis. However, water quality is one of the ORVs for which the river was designated. The final CRMP should therefore explain how increases in recreation use will be managed to ensure that water quality conditions remain consistent with this designation. Explicitly incorporating water-quality indicators into visitor capacity evaluations would strengthen the plan’s ability to prevent incremental degradation over time.

We recommend strengthening the plan by:

  • Designing a comprehensive water-quality monitoring program that identifies monitoring locations along each fork of the river and establishes appropriate monitoring frequency. Monitoring locations should include upstream reference sites, downstream recreation-use areas, and tributaries at heavily used access sites or confluences in order to detect cumulative recreation impacts and allow meaningful comparisons over time. Monitoring should also track recreation-related indicators that influence water quality, including shoreline erosion, campsite proliferation, litter and human waste conditions, access-site disturbance, riparian vegetation condition, and human-caused bank erosion that could increase sediment inputs to the river.

  • Defining measurable monitoring thresholds and corresponding management responses within the adaptive management framework, including triggers such as elevated E. coli, rising water temperatures, declining flows, or BMP failures. These triggers should be clearly linked to specific management actions such as site restoration, temporary closures, sanitation improvements, parking restrictions, angling limitations during periods of thermal stress, or use reductions. The plan should also commit to periodic public reporting on monitoring results and BMP effectiveness, along with scheduled adaptive management evaluations (e.g., every 3–5 years) to determine whether additional management actions are necessary.

The EA identifies localized impacts associated with dispersed recreation sites and access areas. While the CRMP includes important sanitation and BMP measures, additional clarification is needed to ensure these protections remain effective over time. Specifically, the plan should:

  • Clarify how sanitation requirements, gravel-bar camping and parking restrictions, and other Best Management Practices will be implemented, inspected, and enforced, including establishing a clear inspection schedule, documentation protocol, and follow-up corrective action process to ensure identified problems are addressed promptly.

  • Require float parties, particularly at heavily used locations, to contain and pack out solid human waste, given increasing recreation pressure and the sensitivity of this river system.

  • Commit to restoration of degraded access sites and dispersed camping areas where monitoring has identified erosion, human waste, or other impacts, including locations such as Blankenship Bridge, Great Northern Flats, and the Canadian Border access site.

Visitor capacity

The draft CRMP establishes user capacities above current use levels across all river segments, with increases ranging from approximately 11 percent to nearly 300 percent above estimated existing use. The most substantial increases occur in the Middle Fork, where proposed capacities reach nearly three times current estimated use in some segments. This approach appears to assume that existing recreation levels are sustainable and are not degrading ORVs, including water quality and fisheries habitat. Yet, the EA identifies significant impacts associated with recreation at several sites.  

  • The plan would benefit from a clearer explanation of how visitor capacity percentages were estimated and whether current and proposed levels are compatible with protection of the river’s ORVs. Because the EA indicates that water quality was not considered the most sensitive limiting factor in the capacity analysis, the final CRMP should clarify how this ORV was incorporated into that analysis.

Anticipated changes in river conditions, including warmer water temperatures and lower summer flows, will likely concentrate recreation into shorter periods and increase stress on native fisheries and aquatic ecosystems while also increasing the sensitivity of the river system to additional human disturbance and contamination. 

  • The CRMP should therefore evaluate whether increased user capacity is compatible with the long-term protection of cold-water fisheries and water quality and clearly identify climate-related indicators, such as sustained increases in summer water temperature or reductions in base flow, that would trigger additional management actions.

Native Fisheries

The cold, clean Flathead River system provides important habitat for native bull trout and westslope cutthroat trout. Bull trout populations are experiencing long-term declines. The Draft EA notes that angling pressure has increased in recent decades and that additional recreation use may increase fishing pressure and incidental bull trout catch.

  • Because water temperature and summer flow conditions strongly influence habitat suitability for native cold-water species, the CRMP should consider how recreation management actions could be adjusted during periods of elevated thermal stress. For example, temporary reductions in floating or angling activity during periods of unusually warm water temperatures could reduce cumulative stress on native fish populations.

  • To strengthen protection of native fisheries, the CRMP should identify clear thresholds and associated management actions related to angling pressure by establishing indicators, such as changes in catch rates, incidental bull trout encounters, or other fisheries metrics, along with corresponding management responses.

Potential responses could include targeted education, seasonal restrictions in sensitive areas, or other management measures developed in coordination with Montana Fish, Wildlife & Parks.

This Wild and Scenic River corridor offers a unique experience where pristine, clear waters, abundant wildlife, solitude, and tranquility can still inspire awe in residents and visitors alike. The Wild and Scenic River designation was an act of remarkable foresight, intended to preserve the extraordinary landscape and the kind of experience that earlier generations encountered. As opportunities for similar experiences diminish elsewhere and demand continues to grow, we are challenged to maintain these values as they were originally envisioned. This makes it especially important to ensure that the CRMP carefully protects these values and avoids allowing this unique corridor to become an overcrowded destination.

The proposed CRMP contains several strong elements, including recognition of site-specific impacts, sanitation measures to reduce contamination risks, improved monitoring frameworks, and efforts to improve visitor-use data. Strengthening water-quality monitoring commitments, clarifying the role of scenic easements, and providing a clearer framework for translating monitoring results into management actions would help ensure the final CRMP provides a durable foundation for protecting this extraordinary river system.

Thank you for the opportunity to comment and for your continued stewardship of the Flathead Wild and Scenic Rivers.

Sincerely,

Constanza von der Pahlen

Flathead Lakers